Tax

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Why the EU Commission wont appeal the Starbucks judgment  
mnetax.com Dec 10, 2019
When you are winning even when you lose, there is no point in trying too hard. This is why, in a nutshell, the European Commission has decided not to appeal its General Court loss in the Starbucks State aid case, despite the fact that its decision...
Royalty rates for licensed intangibles and minerals
mnetax.com Dec 10, 2019
Like other expressions, economic categories reflect reality, and the term royalty isnt an exception. Michiel de Vaas Etymological Dictionary of Latin and the Other Italic Languages (Brill, 2008) has no entry for royalty or its lemma. See his...
Hong Kong proposes tax cut for insurance-related businesses
mnetax.com Dec 10, 2019
The Hong Kong government on December 6 published a bill proposing to reduce the profits tax rate to 8.25 percent for all general reinsurance business of direct insurers, selected general insurance business of direct insurers, and selected insurance...
OECD holds consultation on 'pillar two' global tax for multinationals, pledges continued work on 'pillar one'
mnetax.com Dec 10, 2019
The OECD on December 9 held a public consultation in Paris, providing a forum for stakeholders to express their views on how to best design a pillar two global minimum tax on multinational group profit, also known as the global anti-base erosion...
Log In MNE Tax WordPress
mnetax.com Dec 9, 2019
Is the US about to blow up the OECD's compromise 'pillar one' plan for taxing multinational group profit?
mnetax.com Dec 5, 2019
In a surprising development, US Treasury Secretary Stephen Mnuchin has revealed that the US no longer supports key elements of the OECDs compromise proposal to overhaul the rules for allocating multinational group profit and related taxing rights...
Netherlands publishes first summaries of private tax rulings issued to MNE groups
mnetax.com Dec 5, 2019
The Netherlands, on October 16, published the first redacted summaries of private tax rulings that have been issued to taxpayers or rejected by the Dutch tax authorities. These rulings were published pursuant to a July 1 update to the Netherlands...
OECD releases 186 comment letters on proposal for global minimum tax on multinational group profit
mnetax.com Dec 4, 2019
The OECD today released 186 comment letters in response to its request for assistance in the design of a global minimum tax on multinational group profit. The OECD also released the agenda for a December 9 public consultation on the minimum tax...
US publishes final and proposed base erosion anti-abuse tax regs
mnetax.com Dec 3, 2019
The US on December 2 released 343 pages of final and proposed regulations on the base erosion and anti-abuse tax (BEAT). The BEAT, added in the 2017 Tax Cuts and Jobs Act (TCJA), aims to prevent large multinational groups from reducing their US tax...
US issues final foreign tax credit regulations
mnetax.com Dec 3, 2019
The US IRS on December 2 issued comprehensive final and temporary regulations addressing the foreign tax credit. The new regs finalize a portion of proposed regulations published on December 7, 2018. These regulations are needed to clarify many...
Australia releases synthesized text of tax treaties with Ireland, India reflecting MLI changes
mnetax.com Dec 3, 2019
The Australian government on November 29 released the synthesized texts of Australias tax treaties with Ireland and India reflecting how those treaties were modified by the later ratification of the Multilateral Convention to Implement Tax Treaty...
Latest EU effort to make country-by-country reporting public fails
mnetax.com Dec 3, 2019
A proposal to make public country-by-country reports on large multinationals held by EU tax administrations has failed in the EU Competitiveness Council (COMPET). A majority of EU nations did not support the measure in a 28 November vote. Some...
US Ninth Circuit rejects request for hearing in key transfer pricing case
mnetax.com Dec 3, 2019
On November 11, the US Court of Appeals for the Ninth Circuit panel reached a decision to reject the request for an en banc hearing in the Altera Corp v. Commissioner transfer pricing case. The decision will have a major impact on multinational...
OECD celebrates Global Forums 10th anniversary
mnetax.com Nov 29, 2019
Tuesday was a great day for OECD-led Global Forum on Transparency and Exchange of Information. More than 386 delegates (64 ministers) from more than 142 jurisdictions met in Paris for the Global Forums 10th anniversary. OECD Secretary-General...
Paris consultation reveals little unity on OECD's 'unified approach' for taxing multinational groups
mnetax.com Nov 26, 2019
More than 100 speakers lined up at a November 2122 Paris consultation to share their views on the OECD Secretariats compromise proposal to update to the rules for allocating multinational group profits and related taxing rights among countries,...
DAC 6 implementation: where European jurisdictions stand
taxand.com Nov 22, 2019
DAC 6 is to be transposed by each Member State into domestic laws by the end of 2019, and the first reporting is due on 31 August 2020 with the first quarterly exchange of information on 30 October 2020. While DAC 6 proposes a uniform mandatory...
Pillars 1 & 2: new profit allocation rules and minimum taxation
taxand.com Nov 22, 2019
Flick Gocke Schaumburg, Taxand Germany, recently hosted a client seminar in Frankfurt to review with clients recent developments relating to the OECDs suggested approaches on new profit allocation rules and minimum taxation, and the latest...
Double Tax Treaty between Peru and Japan
taxand.com Nov 20, 2019
On November 18, Peru and Japan have entered into a Double Taxation Treaty (DTT) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The objective of this agreement is to establish mechanisms...
Danish staffing company cant deduct royalties paid to Swiss parent, High Court rules
mnetax.com Nov 19, 2019
In a key decision, Denmarks Eastern High Court, on 28 October, agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its Swiss parent for the use of marketing intangibles. The 50-page published case...
US Tax Court resolves Eatons transfer pricing dispute
mnetax.com Nov 14, 2019
The US Tax Court issued a written opinion on October 28 regarding Eatons transfer pricing court case. The resolution of the case was in favor of Eaton, and it determined the IRS abused its discretion when canceling advance pricing agreements the...
Implementation of transition law for EU social security rules after a no-deal Brexit
taxand.com Nov 13, 2019
The United Kingdom and the Netherlands have both agreed to implement a transition law to establish that the EU social security rules for cross border situations will still apply for a period of 1 year after a no-deal Brexit. Both countries will...
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